Number 1 – Analyse the business, its risks and compliance gaps – if changes are required prioritise the high risk areas.
Number 2 – Write a compliance plan and agree it at top level.
Number 3 – Consider entering into Compliance Officer Agreements with indemnities and amending COLP and COFA job descriptions as well as employment contracts.
Number 4 – Speak to the firm’s broker about COLP and COFA insurance.
Number 5 – Give unequivocal backing to Compliance Officers and agree resourcing requirements and budgets.
Number 6 – Become an authority on the SRA Handbook 2011 (COLP), the SRA Accounts Rules 2011 (COFA) and other relevant legislation – there are plenty of training events and webinars available – visit www.jonathonbray.com for more information.
Number 7 – Review and update the office manual and other relevant policies and procedures.
Number 8 – Set up suitable data capture and recording systems. If planning to use software get demonstrations from suppliers to ensure they fit with existing systems and work methods.
Number 9 – Set up risk-management system involving regular top level review of the risk register.
Number 10 – Train staff on the requirements of putcomes-focused regulation, their internal reporting duties and any changes made to systems, policies and procedures.
